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I don't follow why the foreign holding company that has all of the Apple money can't just send the money direct to Apple shareholders, avoiding the need to pay American taxes on money transferred to Apple America. The thinking of conservatives is corporations should not have to pay any income tax. Just as with partnerships, taxes on profits should be paid by shareholders when the profits are distributed via dividends.

The tax is applied when the money is repatriated, which Apple would need to do to pay the shareholders.